Swiss Transparency Act: All Information on the Transparency Register

Banks and the discrepancy notification for domiciliary companies

The Transparency Act and its Ordinance do not recognise domiciliary companies and determine the beneficial owner for every legal entity uniformly according to the 25 percent threshold in Art. 4 LETA. Form A under the CDB 20, by contrast, targets the beneficial owners of the assets in the case of a domiciliary company and applies no threshold. The article explains how this gives rise to systemic discrepancies, when a discrepancy notification is owed under Art. 30 LETA and Art. 55 LETO, and when the exception under Art. 56 let. a LETO applies. It also shows which documents a risk-aware bank should obtain in addition to Form A.
July 8, 2026
5 Min.

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AllDue Diligence & Documentation
Reporting & Deadlines
Beneficial Owners
Reporting Obligations
Transparency Register
Reporting Process
Controls & Sanctions
Advisors & Financial Intermediaries
Who is affected?
4 Min.

Documentation and Retention Obligations under the LETA – What Companies Must Record and Retain

The LETA obliges legal entities to comprehensively document all information relating to their beneficial owners and to retain it for ten years. This article explains what data and supporting documents must specifically be recorded and how unsuccessful identification attempts must be documented. It also sets out the requirements regarding currency, access from Switzerland, and long-term availability. Particular attention is given to ensuring the completeness of documentation through personnel and structural changes.

4 Min.

Change Notifications to the Transparency Register: What Needs to Be Reported and When?

The Transparency Register only fulfils its purpose if entries are continuously updated. This article explains which changes are subject to the notification duty, how the procedure via the electronic platform works, and which situations are exceptionally exempt from the notification duty. It also shows why the company needs an internal control system in order to reliably comply with the one-month deadline under Art. 10 LETA. Responsibility remains with the most senior member of the managing body under Art. 12 LETA, who must arrange for the notifications even where they are delegated internally or externally.

4 Min.

Control by Other Means: When a Person Without Shares Still Has to Be Reported to the Transparency Register

Beneficial owners cannot always be identified through shareholdings alone. Control by other means frequently arises through contracts, voting agreements, financing instruments, fiduciary arrangements or family structures. This article explains which constellations trigger a duty to report to the transparency register and what boards of directors, management and founders need to consider when correctly identifying the beneficial owners of their company.

Who May Access the Transparency Register – and Why?

The Transparency Register is not a public register. Access is granted only to statutorily authorised authorities, financial intermediaries, and certain advisors to the extent they require the data for their duties or due diligence obligations. The article explains how authority access, anti-money laundering queries, and logging differ from one another. At its core is the obligation to report discrepancies where register data does not align with other information — creating a control system that continuously improves the quality of the reported data.

7 Min.

Notification Obligations under the LETA: What Shareholders, Members and Beneficial Owners Need to Know Now

The new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (LETA) obliges holders of equity interests holding more than 25 percent to notify the company of the beneficial owner. The notification must be made within one month of acquiring control and must be kept up to date as circumstances change. Notifications already made under Art. 697j CO may be recognised under certain conditions, provided the person notified also qualifies as beneficial owner under the new law. Wilful breaches may be sanctioned with a fine of up to CHF 500,000. A structured approach to maintaining the share register — for example through Konsento — provides the best foundation for meeting the new obligations on time.

4 Min.

Transparency Act: Paper Tiger or Real Control System?

The new Swiss Transparency Act requires companies to report their beneficial owners to the transparency register. Many wonder whether compliance with these duties is actually monitored, or whether the act is merely a paper tiger. This article shows that the TJPG provides for a multi-stage control system involving the register-keeping authority, difference reports, flags and a risk-based supervisory authority. It explains the consequences of incorrect filings and sets out why companies should document their ownership structure properly and well in advance.